Epstein Secrets

nt prosecution agreement with Edwards' counsel, whereby both parties agreed to share information relative to their claims and/or defenses related to Scott Rothstein without waiving privilege as to their communications or documents shared." Edwards' Supp. Resp. to Epstein's Mot. to Declare Relevance, July 26, 201

in (e.g., victims of) Rothstein Rosenfeldt & Adler's Ponzi scheme, in the Razorback litigation. These investors were unquestionably adverse to both Rothstein and Edwards' law firm of which he was a partner. Despite this, Edwards voluntarily produced documents that he now claims are privileged to Mr. Scher

in the substantial equivalent of the materials by other means. A showing of need encompasses a showing of diligence by the party seeking discovery. Proctor & Gamble Co. v. Swilley, 462 So. 2d 1188, 1194 (Fla. 1st DCA 1985). And "No determine whether a moving party will experience undue hardship, courts must balance

ami, FL 3 3160 305-931-2200 Brad Edwards, Esq. Rothstein Rosenfeldt Adler 401 East Las Olas Boulevard Su

under the Federal Rules is to obtain a full and accurate understanding of the true facts in order to obtain a fair and just result. United States v. Proctor & Gamble Co., 356 U.S. 677,682, 78 S.Ct. 983 (1958). 16. Defendant should not have to rely on only those "handpicked" witnesses disclosed by Plaintiff at depo

each, FL 33409 561-686-6300 Brad Edwards, Esq. Rothstein Rosenfeldt Adler 401 East Las Olas Boulevard Su

under the Federal Rules is to obtain a full and accurate understanding of the true facts in order to obtain a fair and just result. United States v. Proctor & Gamble Co., 356 U.S. 677, 682, 78 S.Ct. 983 (1958). 16. Defendant should not have to rely on only those "handpicked" witnesses disclosed by Plaintiff at dep